IR 05000133/2011002
| ML11195A341 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 07/14/2011 |
| From: | Spitzberg D Division of Nuclear Materials Safety IV |
| To: | Conway J Pacific Gas & Electric Co |
| References | |
| IR-11-002 | |
| Download: ML11195A341 (14) | |
Text
July 14, 2011
SUBJECT:
NRC INSPECTION REPORT 050-00133/11-002
Dear Mr. Conway:
This refers to the inspection conducted on June 13-16, 2011, at the Humboldt Bay Power Plant, Unit 3 facility, in Eureka, California. The enclosed report presents the results of this inspection.
This inspection was an examination of activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. In summary, the inspector determined that you were conducting decommissioning activities in accordance with license and regulatory requirements. The preliminary inspection results were presented to your staff at the conclusion of the onsite inspection. The enclosed report presents the results of this inspection
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs documents system (ADAMS), accessible from the NRCs Web site at HTTP://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.
Should you have any questions concerning this inspection, please contact Dr. Gerald Schlapper, Health Physicist at 817-860-8273 or the undersigned at 817-860-8191.
Sincerely,
/RA/
D. Blair Spitzberg, PhD, Chief
Repository & Spent Fuel Safety Branch
Docket: 050-00133 License: DPR-7 UNITED STATES NUCLEAR REGULATORY COMM ISSION R E GI ON I V 612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 76011-4125
Pacific Gas and Electric Company
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Enclosure:
NRC Inspection Report 050-00133/11-002
REGION IV==
Docket:
050-00133
License:
Report:
050-00133/11-002 Licensee:
Pacific Gas and Electric Company
Facility:
Humboldt Bay Power Plant, Unit 3
Location:
1000 King Salmon Avenue
Eureka, California 95503
Dates:
June 13-16, 2011
Inspector:
Gerald Schlapper, PhD, PE, CHP, Health Physicist
Repository & Spent Fuel Safety Branch
Approved by: D. Blair Spitzberg, PhD, Chief
Repository & Spent Fuel Safety Branch
Attachment:
Supplemental Inspection Information
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ENCLOSURE EXECUTIVE SUMMARY
Humboldt Bay Power Plant, Unit 3 NRC Inspection Report 050-00133/11-002
This inspection was a routine, announced inspection of decommissioning activities being conducted at the Humboldt Bay Power Plant (HBPP), Unit 3 facility. In summary, the licensee was conducting site activities in compliance with regulatory and license requirements.
Safety Reviews, Design Changes and Modifications
The licensee conducted safety reviews, design changes and modifications in accordance with license and regulatory requirements (Section 1).
Decommissioning Performance and Status Review
The licensee conducted decommissioning activities in accordance with license and regulatory requirements. Radioactive postings and boundaries were maintained in accordance with regulatory requirements. Contaminated equipment and material characterization and removal work was conducted in accordance with procedure requirements (Section 2).
Radioactive Waste Treatment and Effluent and Environmental Monitoring
The licensee conducted radioactive waste treatment and effluent and environmental monitoring in accordance with license and regulatory requirements (Section 3).
Radioactive Waste Management and Transportation
The licensee conducted radioactive waste management and transportation in accordance with regulatory requirements (Section 4).
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ENCLOSURE Report Details
Summary of Plant Status - Unit 3
During the inspection, the Humboldt Bay Power Plant (HBPP), Unit 3, was being decommissioned by the licensee in accordance with commitments made in its Post Shutdown Decommissioning Activities Report dated June 30, 2009. The licensee has completed the process of analyzing options and has decided to section the reactor vessel for removal. The licensee has issued a request for proposal for this effort which is scheduled to begin during 2012.
Decommissioning of the adjacent fossil plants, Units 1 and 2, is progressing on schedule. A contractor continues this effort as a turn-key project. The decommissioning of Units 1 and 2 is projected to be completed in August of 2011, and is being done concurrent with the ongoing Unit 3 decommissioning activities.
During the inspection, the inspector reviewed storage and controls associated with source accountability and usage to validate that these procedures continued to be effective. Newly installed and calibrated monitoring systems for incoming and outgoing truck shipments are operational and are used to radiologically monitor trucks hauling building rubble from Units 1 and 2 to further ensure that the building debris meets the criteria for alternate disposal in accordance with the NRC approval letter dated November 2, 2010.
Safety Reviews, Design Changes and Modifications. (37801)
1.1 Inspection Scope
The inspector evaluated whether the licensee conduct of safety reviews, design changes and modifications were in accordance with license and regulatory requirements.
1.2 Observations
On August 21, 2010, the licensee accidently spilled radioactive liquid inside the restricted area. An engineering design change of the liquid radwaste system had recently been completed. This was the first time the system had been operated in the new configuration. Independent review of the problem and analysis of corrective actions determined that operations personnel need to be more involved in the design process and that there needs to be a stronger coupling of engineering design changes to procedural changes. Detailed procedures were developed to ensure these actions occurred. The inspector reviewed implementation of these procedures, talked with licensee personnel and determined that implementation of these procedures had prevented recurrence of similar problems. The inspector attended lessons learned discussions conducted with site supervisors and managers on use of these procedures.
Participants in the discussions noted the overall success of the effort and recognized the need for their continued involvement in the processes.
General labor during decommissioning of Unit 3 is supplied by a subcontractor, Day-Zimmerman. The inspector met with the site manager and staff of the contractor and observed a commitment to safe operations. The site manager noted that his supervisors no longer discuss schedule needs during meetings that describe work to be conducted.
The inspector attended a meeting for all of the labor force. Without prompting from
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ENCLOSURE management the employees led off the discussion reciting the need to be safe in all activities. Discussion with selected laborers indicated satisfaction with the emphasis on training and safety.
The inspector attended a general discussion involving workers, senior staff and managers of the removal of components from the reactor vessel to storage in the spent fuel pool. Because this work is infrequent, unique and high risk, senior management to include the PG&E Site Director was involved. After presentations by project and operations personnel, workers discussed their concerns. Use of a dry run test was noted and the fact that prior to the actual lifts, additional safety discussions and briefings would take place as required. Individuals responsible for key areas were named and they acknowledged their responsibilities and commitments. Emphasis by the site director and senior management in attendance was to focus on work, not schedule for this activity.
Major high risk activities on-site are also reviewed by the Site Readiness Review Board to ensure that planning is complete, required equipment is available and that work is ready to proceed. The Board, a site decision making entity, is led by the Site Director with all major site managers or their designees in attendance. The inspector attended a meeting of this Board where the lift of a major component in the reactor vessel area, known as the chimney, was central to the discussion. The contractor project lead for this effort presented the proposed effort to move the chimney component and place it on the floor of the refueling pool for further processing. Details of the effort, specific requirements and concerns were presented and discussed.
1.3 Conclusions
The licensee conducted safety reviews, design changes and modifications in accordance with license and regulatory requirements.
Decommissioning Performance and Status Review (71801)
2.1 Inspection Scope
The inspector evaluated whether the licensee and its contracted workforce were conducting decommissioning activities in accordance with license and regulatory requirements.
2.2 Observations
Currently the project is on time and within budget. The inspector observed ongoing work in the reactor building. At the time the inspector was in the building, workers, following a valid RWP, were actively cleaning the floor area near the spent fuel pool and taping pathways in preparation for transfer of material from the reactor vessel into the spent fuel pool where size reduction and other activities would take place. When a worker was asked by the inspector what activity was underway, the worker noted that they were removing unnecessary items and preparing the area to limit possibility of contamination and generation of airborne material. The inspector also toured the counting laboratory and verified that workers were continuing to follow procedures applicable to control of sealed and calibration sources. While walking the site, the inspector approached the
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ENCLOSURE area where transportation containers are prepared for loading. Workers were observed to be in compliance with requirements of the applicable Radiation Work Permit (RWP).
The inspector toured the radiologically restricted and unrestricted areas of the facility and observed ongoing work. Radiological postings on fences and at entrances to the restricted area were clearly visible, and postings met the requirements of 10 CFR Part 20. During site tours, the inspector conducted radiological surveys to verify the accuracy of radiation boundary postings using a Ludlum Model 2401-EC2 survey meter (NRC Number 21116G, calibration due date of 12/06/11). The inspector did not identify any location that was incorrectly posted by the license. The inspector entered one area with limited stay time. Upon entry it was noted that a radiation protection technician was watching time and did as required by procedure notify the inspector that it was time to exit the area. The inspector visited an area where preparations were underway for cutting sections of contaminated pipe. Workers noted that piping removal now uses a spray fixative in the pipe to limit release of contamination. Use of ventilation and glove bag enclosures was also noted.
The HBPP maintains a series of trending documents to allow for assessment of radiation protection performance. The inspector emphasized review of data since the last inspection for external and internal exposures related to decommissioning activities.
Through May 2011, actual exposures were 10.7 man-rem compared to an estimate based on a similar facility of 41.1 man-rem for the same timeframe of work. Essentially all of the exposure was external in nature. The reduction in actual exposure is due in part to use of shielding, selected hot spot removal and effective cleanup of reactor vessel water. Due to concerns of exposure to airborne alpha emitters, the licensee relies on lapel air samplers to assess the level of airborne exposure. During 2011 through May, 2708 lapel samplers were issued. This compares to a total of 2855 for all of 2010 and is a reflection of the increased level of decommissioning activity. The inspector visited the room in the access control center where lapel samplers and respirators are issued. The inspector talked with the workers who described the procedure followed and then demonstrated tests conducted on lapel air samplers prior to issuance and upon return after work completion. The workers were knowledgeable of requirements to include need for traceability to National Institute of Standards and Technology (NIST) standards. Because of the very low exposure levels, direct measurements using bioassay techniques cannot be used to assess routine exposure, and calculation of exposure levels based on lapel air sampling results is required.
2.3 Conclusions
The licensee conducted decommissioning activities in accordance with license and regulatory requirements. Radioactive postings and boundaries were maintained in accordance with regulatory requirements. The inspector observed ongoing work and noted that it was conducted following procedures and in accordance with license and regulatory requirements
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ENCLOSURE
Radioactive Waste Treatment and Effluent and Environmental Monitoring (84750)
3.1 Inspection Scope
The inspector reviewed radioactive waste treatment activities and effluent and environmental monitoring programs to determine whether the licensee conducted these efforts in accordance with license and regulatory requirements.
3.2 Observations
The inspector reviewed the Annual Radiological Environmental Monitoring Report for 2010 dated April 29, 2011. The report provides a description of the Radiological Environmental Monitoring Program (REMP) and includes tables and figures describing sampling locations on-site and off-site along with monitoring results in the form of summaries and tables. Also the report provides summaries, interpretations and analysis of trends. The monitoring efforts provide data on radiation levels and radioactive materials in those exposure pathways and for those radionuclides that have the highest potential for exposure of the workers and public. Results indicate that decommissioning activities have had no measurable radiological impact on the environment. Annual offsite doses due to the direct radiation pathway are within ranges that have existed for over a decade. On-site station data as presented in Table C-2 of the environmental monitoring report shows that levels are in the same range as dose levels for off-site station locations (Table C-3) which indicates that even on-site, exposure levels are approximately equal to background.
For the surface water pathway, the Off-site Dose Calculation Manual Model is based on the average concentration of radioactivity released and diluted by the tidal flow of water in the outfall canal. Prior to shutdown of the two fossil units, that are currently undergoing decommissioning, dilution of water in the discharge canal was supplied by flow of coolant water through these units. The present weekly tidal flow volume is conservatively estimated to be 7 million gallons and thus for a week long composite sample one would not expect that concentrations of radioactivity to exceed minimal detectable levels. Results for discharge activities as presented in Table C-4 of the environmental report show gamma and tritium activity levels less than minimum detectable levels. The licensee noted by observation of the discharge canal at low tide that there is an inflow of silt material. This inflow of silt which was not a problem when the fossil units were in operation, will act to reduce the volume of the canal and thus the amount of weekly tidal flow. The licensee using a GPS system had previously mapped the buildup of silt and determined that sufficient volume was still available and that dilution factors were still valid. During the inspection, the inspector observed staff conducting another detailed measurement to note the amount of change in silt level and its impact on dilution. The licensee noted that such measurements will continue in order to validate use of appropriate dilution factors for releases of radioactive liquid waste into the discharge canal.
3.3 Conclusions
The licensee conducted radioactive waste treatment and effluent and environmental monitoring in accordance with license and regulatory requirements.
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Solid Radioactive Waste Management and Transportation (86750)
4.1 Inspection Scope
The inspector reviewed the licensees programs for radioactive waste management and transportation of material for disposal.
4.2 Observations and Findings
For the period January through May 2011 the site has made 25 shipments of Class A waste to the Energy Solutions site located in Clive, Utah. By letter of November 2, 2010, NRC approved of alternate disposal of Resource Conservation and Recovery Act (RCRA) waste containing low-activity radioactive material. Since that time, a total of 127 shipments consisting of RCRA waste primarily from the decommissioning of fossil Units 1,2 with only limited amounts from Unit 3 were made to the US Ecology site in Grand View, Idaho. In addition, there were 148 shipments of recycle waste sent to local recycle facilities and local landfills. This waste was generated during the decommissioning of areas of the fossil units that from historical information was known to not have had any radioactive material present. This knowledge was complemented by well documented surveys of the material by radiation protection personnel. Once packaged, shipments are subjected to a final survey by radiation protection and waste packaging personnel for compliance with applicable limits. As a final check and prior to exiting the site, the transport vehicles to the Idaho site or local recycle or disposal pass through a vehicle portal monitor, set to alarm if contents exceed acceptable limits. The inspector observed this process during this inspection. The licensee noted that they have had no citations, violations, findings or Non-Compliance Reports from Federal or State Departments of Transportation or the disposal sites. Required compliance training in general awareness, radioactive waste packaging and shipping, and shipper certification is provided on site to appropriate personnel.
By letter dated June 7, 2011, the licensee requested NRC approval for alternate disposal of approximately 2 million cubic feet of hazardous waste containing low-activity radioactive debris. The request is made under the alternate disposal provision in 10 CFR 20.2002 and the exemption revision of 10 CFR 30.11. The request is to cover material generated during the demolition of structures and site remediation activities related to the decommissioning of the Unit 3 site. Other than the increased volume (2 million compared to 200,000 cubic feet) and the source of the material (primarily Unit 3 rather that primarily Units 1,2) this is in concept similar to the licensees previous request for the material originating from Units 1 and 2.
4.3 Conclusions
The licensee conducted radioactive waste management and transportation activities in accordance with license and regulatory requirements.
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Exit Meeting
The inspector reviewed the scope and preliminary findings of the inspection during an exit meeting that was conducted at the conclusion of the onsite inspection on June 16, 2011. The licensee did not identify as proprietary any information provided to, or reviewed, by the inspector.
ATTACHMENT SUPPLEMENTAL INSPECTION INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
J. Albers, Radiation Protection Manager B. Arroyo, Site Services Manager A. Berry, Radwaste Supervisor J. Costantino, General RP Foreman A. Cordone, Decommissioning Projects Superintendent S. Davis, Site Manager, Day and Zimmerman J. Griffin, Licensing Engineer S. Jones, QA Supervisor S. McDonald, Safety/IH Department Supervisor D. Pierce, Area Supervisor P. Roller, Director and Nuclear Plant Manager S. Schlerf, Radiation Protection Forman B. Sicotte, QC Supervisor D. Sokolsky, Licensing Supervisor
INSPECTION PROCEDURES USED
IP 37810 Safety Reviews, Design Changes and Modifications
IP 71810 Decommissioning Performance and Status Review IP 84750 Radioactive Waste Treatment and Effluent and Environmental Monitoring IP 86750 Radioactive Waste Management and Transportation
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
None
Discussed
None
ATTACHMENT
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LIST OF ACRONYMS
CFR
Code of Federal Regulations HBPP Humboldt Bay Power Plant IP
NRC Inspection Procedure ISFSI independent spent fuel storage installation NIST National Institute of Standards and Technology ODCM Offsite Dose Calculation Manual RCRA Resource Conservation and Recovery Act RWP Radiation Work Permit